WHO WE ARE

JB Publications, Inc. (“JB Publications”, we,” or “us) provide people the ability to create, learn and teach music as well as internal and third-party applications to help us with business related tasks like accounting, marketing, and troubleshooting (the “Services”). JB Publications owns and operates the website: jbpublish.com

Some of the data JB Publications collects is considered “personally identifiable information,” “personal information” or “personal data” under applicable law (collectively referred to in this Privacy Policy as “Personal Data”). Generally, Personal Data is information that can be reasonably connected to an identified or identifiable individual. It does not include deidentified or anonymized data.

The purpose of this Privacy Policy is to disclose to you how we collect, use and share Personal Data and how we attempt to safeguard the Personal Data we collect and process. We are committed to securing the Personal data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws. We may update this Privacy Policy from time to time. When we do, we will post an amended version of the Privacy Policy on this website. Please review this Privacy Policy periodically. Please note, the JB Publications Cloud application (home.JB Publications.com and associated subdomains) is subject to a separate Privacy Policy with additional information.

HOW TO CONTACT US

If you have any questions regarding data protection or your rights, please contact us:

• JB Publications
• 1224 US-377, Ste 303278
• Roanoke, TX 76262
• Visit us at support.JB Publications.com
• Email us at john@jbpublish.com
• Call us toll free (for the U.S.A.): 1-800-843-2066
• International callers: (952) 937-9611

WHY WE COLLECT DATA AND HOW WE COLLECT IT

We collect, process and use Personal Data to allow you to provide our products, Services and Sites to you. For example, we use the Personal Data we collect to:

• Communicate with you;
• Provide you with information, quotes and offers;
• Provide our Sites and Services;
• Process your account registration (where applicable);
• Provide you with support;
• Personalize and / or enhance your experience on our Sites;
• Provide information about data privacy and security;
• Measure the performance of our Sites and Services;
• Assist with ensuring the security and integrity of the Sites and Services;
• Maintain, improve and customize our products, Sites and Services;
• Investigate, prevent or take action regarding illegal activities, suspected fraud or violations of our terms of use;
• Efficiently maintain our business;
• Comply with applicable law; and
• Defend our legal rights and the rights of others.

We obtain Personal Data directly from you, through cookies and other technologies, through your devices, and from third parties as described in this Policy and any other privacy notices we may provide to you when you interact with us.

PROTECTING YOUR PRIVACY GENERALLY

• Industry-Standard Protection. We utilize industry-standard security measures to safeguard the information we collect, maintain and use. These measures include technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration or destruction. However, we do not and cannot guarantee the performance or adequacy of such security measures.
• Limitation on Access Access to any Personal Data we collect and store is generally restricted to our employees and/or contractors who require it to perform a job or other contracted function. We require vendors and contractors we work with to use reasonable, industry standard protocols to maintain the confidentiality, security, and integrity of Personal Data.
• Third Party ProcessorsTo ensure that your Personal Data receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your Personal Data with to ensure that your Personal Data is treated by those third parties in a way that is consistent with applicable data privacy and security laws.

COMMITMENT TO CHILDRENS PRIVACY

• General In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C., § 6501-06 and 16 C.F.R., §§ 312.1-312.12, the Sites do not collect information from children under 13 years of age in the United States without the consent of a parent or legal guardian or another legally recognized consent mechanism. The Sites do not collect information from children under 18 years of age in Canada, or under 16 years of age in the European Economic Area without the legally mandated consent or under a recognized exception. You, as a parent or guardian of a student under the designated minimum legal age may contact us through any of the methods below to request (1) what information we have about such child, (2) that we correct any incorrect information, (3) that we delete any personal data of such child, and/or (4) that we cease further collection or use of any personal data of such child.
• Educational Use Children under 13 years of age in the United States may use the Sites as part of an educational program wherein the respective educational institutions are responsible for collecting required parental consent for children using the Services for educational purposes or are providing parental consent for such student use as allowed under applicable law. For all students in the United States, their use of the Sites is compliant with Family Educational Rights and Privacy Act (FERPA) under the “School Official Provision 34 C.F.R. § 99.31(a)(1)(i)(B).

TYPES OF INFORMATION WE COLLECT

Information You Provide Directly To Us We may collect the following categories of Personal Data if you provide it to us:

• Contact information and identifiers (such as name, local and permanent address, company name, telephone number, electronic mail address);
• Information regarding your order(s) and/or service request(s) (product purchased, date of purchase, purchase price);
• Financial information, such as payment information, from educational institutions and individuals that purchase our products or services;
• Information you provide to us when inquiring about our products or services;
• Any other information you provide to us, including both private messages and user generated, publicly posted content.

Information We Collect Via Tracking Technology.

We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “cookies”) to collect information as you navigate the Sites. Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets). The information collected includes:

• Unique personal identifiers (device identifiers, IP address, cookies, beacons, pixel tags, mobile ad identifiers and other forms or persistent or probabilistic identifiers that can be used to identify a particular consumer or device);
• Internet or other electronic network activity information (browsing history; search history; and information regarding your interaction with website, application or advertisement);
• Device and browser types, language, age category, gender (if available) and interest categories derived from browsing history;
• Your general location data (town or city, not precise location data)

For more information on our use of tracking technologies and to make changes to your settings, please visit our Cookie Policy, which is accessible on the lower right hand portion of our Sites.

• Information Educational Institutions Provide to Us We may collect Personal Data from the educational institutions that utilize our products. The educational institutions may provide Personal Data about you to us if the information is needed to set up an account for you, provide you with services and/or provide you with support and information.
• Non-Identifiable Information. We collect and use non-personally identifiable user information (“Non-PII”) for several purposes, including (without limitation): (i) to calculate necessary royalty payments to third party content providers, which are often based on the number of times a work is opened or accessed by our users; (ii) to prepare reports and other materials that we may share with others in an anonymous format; and
• for analytics purposes. In some instances, we use third-party vendors to collect, monitor and/or maintain Non-PII. For example, we utilize Rollbar, Google SSO and Google Analytics. Rollbar is utilized for error monitoring. Information logged includes common request data. Google Analytics is utilized to analyze application, feature and content usage.

DO NOT TRACK SIGNALS

Some internet browsers incorporate “Do Not Track” or other privacy control features that signal to websites you visit that you do not want to have your online activity tracked. Our cookie management tools respond to these signals.

INFORMATION WE DISCLOSE TO THIRD PARTIES

We may provide access to Personal Data to others in the following ways:

• With Service Providers We may share information with service providers who:
• perform data services on our behalf, such as hosting and cloud storage services (WordPress VIP, AWS);
• prepare, deploy and analyze advertising content on our behalf Google Advertising, Google Analytics, Meta;
• provide other services on our behalf, such as error logging, accounting software services, client relationship management services and other various business services WordPress VIP, Netsuite, Segment (Twillio);
• customer engagement services, customer support services, and customer relationship management services (Engage (Twilio), Hubspot, ZenDesk);
• process payment information on our behalf Braintree; and
• provide cookie and privacy management services on our behalf (OneTrust)
• With Our Affiliates We share information with our affiliated companies, including:
• Our sister companies Alfred Music and Fons and our parent company Peaksware Holdings, LLC, with whom we partner with to utilize common resources, business operations, and for general business purposes (together with JB Publications, Inc., the “Music Brands” or “Family of Brands”).
• To Meet Our Legal Requirements or Exercise Our RightsWe may share information with third parties in the following instances:
• When we are required to do so by law.
• In connection with any legal proceedings or prospective legal proceedings.
• To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention.
• When we reasonably believe it is appropriate to apply to a court or other competent authority for disclosure of that Personal Data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal data.
• We may share information with other persons or entities as part of our own corporate transactions, such as during financing or any asset sale.
• At Your Request We will share your Personal Data when you request or otherwise consent to the disclosures.
• JB Publications CloudFor additional information concerning third party processing for the JB Publications Cloud application, please see the JB Publications Cloud Privacy Policy

HOW TO ACCESS & CONTROL YOUR PERSONAL DATA

We respect your privacy and provide ways for you to choose whether to share your information with us or any third parties

• You may decline to provide information You have the right to decide not to share information with us.
• You may request deletion You may submit a request to update or delete your personal data by contacting us through any of the methods provided on our Contact Us page, or you may email us at john@jbpublish.com
• PLEASE NOTE, HOWEVER, THAT IF YOU CHOOSE NOT TO PROVIDE US WITH CERTAIN INFORMATION OR ASK US TO DELETE YOUR INFORMATION, WE MAY NOT BE ABLE TO PROVIDE YOU WITH ACCESS TO SOME OF OUR SITES AND/OR SERVICES. IN ADDITION, IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO MODIFY OR DELETE DATA DUE TO OUR OWN OBLIGATIONS.
• You may review and request changes to your personal dataIf you have an account with us, you may use your account to access, correct, or view certain personal data we have collected which is associated with your account. You may also contact us through any of the methods provided on our Contact Us page or you may email us at john@jbpublish.com to request information or changes
• You may opt out of marketing communications. You can always choose whether you wish to receive communications we send via email, SMS messages, telephone calls and postal mail. To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails or adjust preferences in your account if applicable. You may also contact us through any of the methods provided on our Contact Us page or you may email us at john@jbpublish.com to opt out of our communications.
• You may control cookies used. You may opt out of cookies through your account settings in the Sites or as described in Section 6 (b) above.

SECURITY

When you register for an account with us, you may be required to choose or will be assigned a password which enables you to access our Sites and Services. You are responsible for keeping this password confidential and for all activity that takes place through your account credentials. Do not share your password with anyone. If your password is compromised, change your password within your account. If you believe your account may have been compromised, please notify us immediately.

We take industry standard security measures to protect your information. We also have put into place appropriate agreements and/or procedures with our service providers to ensure that your Personal Data is treated consistent with applicable data privacy and security laws. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot and do not guarantee the security of your data.

LINKS TO THIRD-PARTY SITES

Our Sites may contain links to other websites and companies that may be of interest to you. If you click on any of those links, you will leave our Sites. We are not responsible for third-party websites. Therefore, please consult the terms of service and privacy policies of those sites when you visit them.

DATA RETENTION

We will store your Personal Data for as long as: (a) you maintain an account with us; (b) you continue using our Sites and Services; (c) your Personal Data is stored in our back up servers and/or services; (d) in accordance with our retention policies and schedules; and (e) as long as we are legally required to retain the Personal Data. Data can be deleted upon request.

Generally, we will store your information for as long as you are a customer and for up to five (5) years thereafter to preserve records in case of a legal claim. We may keep records of transactions with you for a period of up to seven (7) years to comply with the IRS requirements. For users who are students of U.S. educational institutions that are using the Sites and Services and are subject to the Family Educational Rights and Privacy Act (FERPA) and/or where the school has provided consent for us to collect the students personal data under the Children’s Online Privacy Protection Act (COPPA), your data will be kept for as long as you are a customer or until an educator, administrator, or parent/guardian associated with your account requests the removal of your information, unless and only to the extent we have a superseding legal obligation to retain the data.

Because we cannot predict the exact date or time a customer chooses to stop use of our sites and services, data is retained only as long as necessary as determined by the customers. Data may be deleted upon request.

ACCESSIBILITY

We value all of our users, and it is our goal to provide an excellent experience for all our users, including our users with disabilities. You understand and accept, however, that some of the features of the Site and Services may not be fully accessible because they are provided by third- parties or have errors. If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing on our Sites or Services, please email us at accessibility@JBPublications.com You expressly agree to attempt to resolve any and all issues with accessibility directly with us and in good faith prior to instituting any legal action against us.

ADVERTISEMENT AND MARKETING

JB Publications will only market and advertise to customers who have opted in to applicable marketing and/or have their cookie preferences set to enable or accept preference, statistics, and/or marketing cookies. We do not knowingly market to children under the age of 18.

If you are of an age of legal consent in your country, and you opt into receiving such notices, we may use your email address to send you information about changes or improvements we are making, or other JB Publications marketing promotions. Our Business Affiliates, as detailed in Section 8.b. and referred to as (together with JB Publications, Inc.) our “Music Brands” or “Family of Brands,” may also use your provided information to send you marketing communications. To opt-out of this activity, users may opt-out of receiving marketing and advertising material as detailed in Section 9.d.

Customers may also sign up for or opt-in to receive marketing and advertising communications from us at live or digital events. Such events include, but are not limited to, webinars and digital events, trade shows, clinics, and other live events. Customers may submit information to us at these events in a variety of manners including, but not limited to, in-person sign-up, lead-retrieval systems, physical paper coupons or forms, or internet-based forms such as a Google Form. Information received from customers through these means will be treated as described in this section, specifically the second paragraph. Customers who wish to opt-out may do so as detailed in Section 9.d.

AUTOMATED DECISION MAKING

In order to personalize your experience and interactions with our sites and service, JB Publications may use Automated Decision Making (ADM) to optimize product suggestions and personalization, feature interactions, and event firings. To opt-out of such ADM features, customers may opt-out of marketing and advertising services via their account or link at the bottom of applicable emails. By opting-out of receiving marketing or advertisements, customers will successfully opt-out of ADM.

NOTICE TO USERS OF JB Publications CLOUD

Please note that the JB Publications Cloud application is subject to separate Privacy Policy terms. If you use JB Publications Cloud, please carefully review the Privacy Policy.

Likewise, for users utilizing Google API Services for JB Publications Cloud, please read the section “Notice to Google API Service Users” in the JB Publications Privacy Policy for information regarding how your data is handled.

NOTICE OF STATE PRIVACY RIGHTS

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see Section 19. NOTICE TO CALIFORNIA RESIDENTS below. For other state residents, your privacy rights may include (if applicable):

• The right to confirm whether or not we are processing your personal data and to access such personal data;
• The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
• The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights.
• We may use cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This use may be considered “targeted advertising” or “sharing” under applicable privacy laws. To opt-out, please go to your cookie settings and turn off Marketing and Advertising cookies and all other non-Necessary cookies. You may adjust your cookie preferences by visiting our JB Publications and selecting the widget tool in the bottom left corner.
• We do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.
• If you have questions or would like to submit a request to exercise your rights, please call us at 1-800-843-2066 or email us at JB Publications Privacy Policy If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above.
• If you would like to opt out of sales and targeted advertising, please go to your cookie settings and turn off Marketing and Advertising cookies and all other non-Necessary cookies. You may adjust your cookie preferences by visiting JB Publications and selecting the widget tool in the bottom left corner.
• Users who opt-in to receive marketing communications via marketing preferences may receive targeted advertising. See Section 14. ADVERTISEMENT AND MARKETING for more information and how to adjust preferences.

NOTICE TO NEVADA RESIDENTS

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to JB Publications Privacy Policy

NOTICE TO CALIFORNIA RESIDENTS

This Privacy Notice to California Consumers (“CA Notice”) is for California residents and supplements the other sections of JB Publicationss Privacy Policy. This CA Notice explains how we collect, use and disclose your Personal Information” (as that term is defined by California law) and how you may exercise your rights under the California Consumer Privacy Act (“CCPA). This Notice is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you.

• NOTE If you are a Californian resident and a current or former employee, job applicant or independent contractor of JB Publications please see our Privacy Policy for California Employees, Former Employees & Job Applicants for more information on our collection, use and storage of your Personal Information in that capacity.
• NOTICE AT COLLECTION OF PERSONAL INFORMATION To provide you with our products, Sites and Services, we collect and process information about you, including in some cases, Personal Information. To comply with the CCPA and to assist you in understanding our data collection and protection practices during the past 12 months
• Categories of Consumer Personal Information. We collect and, in the 12 months prior to the Date of Last Revision of this Privacy Policy, have collected the following categories of consumer Personal Information:
• Identifiers (name, alias, account name, email address, postal address, Internet Protocol address, online identifiers, other similar identifiers). Unique personal identifiers (cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology).
• Telephone numbers.
• Internet or other electronic network activity information (browsing history; search history; and information regarding an individuals interaction with a website, application or advertisement).
• Commercial information (records of products or services purchased, obtained, or considered, or other commercial information),
• Inferences drawn from above information to create a profile about a consumer reflecting the consumers preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
• Geolocation data.
• Education information, including professional certifications and licenses
• Professional or employment-related information (including employment history).
• Sources of Personal Information. We collect the above categories of consumer Personal Information from you, from your devices and from our distributors and service providers as described in Section 6 above.
• Purpose for Collection. In addition to the business purposes for which we collect consumer Personal Data described in Section 3 above, we collect consumer Personal Information for the following business or commercial purposes:
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
• Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
• Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
• Sale, Sharing and Disclosure of Personal Information We do not sell” Personal Information, as that term is commonly interpreted. However, we do engage in targeted advertising activities that may constitute a sale or a share of Personal Information under California law. Specifically, we use Google Ad Manager, which places tools on our site to collect information from our site users so that Google may serve those users with targeted advertisements through other websites. The following table identifies the categories of Personal Information that Google has collected from our website users in the 12 months preceding the Date of Last Revision of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

• Childrens Personal Information We do not knowingly collect Personal Information of consumers under 16 years of age and we do not knowingly sell or share for advertising purposes the Personal Information of consumers under 16 years of age.
• Sensitive Personal Information. We do not use Sensitive Personal Information (as it is defined in the CCPA) for the purpose of inferring characteristics about individuals.
• Retention of Personal Information. We retain Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
• Your RightsUnder the CCPA, you have the following rights:

How to Exercise Your Rights

• Right to Submit a Request to Know, Delete and/or Correct: You may submit a request to know, delete and/or correct by emailing us at JB Publications Privacy Policy or you may call us at 1-800-843-2066. If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

DO NOT SELL OR SHARE MY PERSONAL INFORMATION. Right to Opt Out of Sale

• You have the right to opt-out of the sales of your Personal Information and the sharing of your Personal Information for cross context behavioral marketing. As set forth above, we do not sell your Personal Information, but can note in our records that you would like to opt out of any future sales by emailing us at JB Publications Privacy Policy or you may call us at 1-800-843- 2066. To opt out of sharing of your Personal Information via cross context behavioral advertising, please go to our cookie settings and turn off Marketing and Advertising cookies and all other non-Necessary cookies. You may adjust your cookie preferences by visiting our JB Publications.com and selecting the widget tool in the bottom left corner.
• Our Process for Verifying a Request to Know, Delete, and/or CorrectWe will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
• Shine the Light Law California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties direct marketing purposes (as those terms are defined in that statute). JB Publications does not sell or disclose information to third parties for their direct marketing purposes.

NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA

The General Data Protection Regulation (“GDPR”) applies to individuals located in the European Economic Area (“EEA). The GDPR allows us to collect and use personal information from individuals within the EEA only for one or more of the following reasons:

• To fulfill a contract we have with you;
• When we have a legal duty;
• When it is in our legitimate interest; or
• When you provide consent.

Some of our website users, customers and prospective customers could be located within the EEA. If you reside in the EEA, you have a number of rights under data protection laws in relation to the way we process your Personal Data, which are set forth below. You may contact us directly to exercise any of these rights, and we will verify your request and, if appropriate, respond to any request received from you within one month from the date of the request. In exceptional circumstances we may need to extend this timescale, but we will always tell you in advance if we do, and our reasons why.